20221115Comments(2)_2.pdf

From:Steven Bravo ([e-mail]) Sent You a Personal Message
To:Jan Noriyuki
Subject:IPC-E-22-22 Public Comment
Date:Tuesday, November 15, 2022 12:02:41 AM
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Dear Idaho Public Utilities Commission,
Idaho power is trying to protect profits. If they are to get serious about a clean environment they need to step up to
the plate.
Please don?t let them make their own decisions on this matter!
Please look carefully at the independent study conducted by Crossborder Energy, which points out several
shortcomings in Idaho Power's own study on the costs and benefits of customer-owned rooftop solar. Idaho Power
will use this study to justify trying to reduce compensation rates to solar owners. To arrive at fair rates, we first
need a fair study.
Crossborder's study states, "We conclude that Idaho Power?s choice of assumptions and calculation methods
significantly undervalue the five components that the utility quantified. We present our own calculations of an ECR
with these five elements. In addition, the VODER Study fails to quantify important benefits of distributed solar that
the Commission directed the utility to analyze in Order No. 35284 -- benefits that are known and measurable, will
impact rates, and will benefit Idaho ratepayers and citizens.?
Idahoans deserve solar rates based on a more fair and complete analysis. I urge you to reject Idaho Power's study
and look to Crossborder's study as a more accurate measure of the value (to ALL ratepayers) of customer-owned
solar power.
Sincerely,
Steven Bravo
10280 Gamann Dr.
Cascade, ID 83611
[e-mail]
[phone]
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tPc-E-22-22
David Chamberlain
Eagle, lD
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Summary
I oppose the ldaho Power VODER study & proposal, but I do have some alternative proposals to
consider
My Solar Experience
I am new to solar. Not an expert at the system, the lingo, and ldaho Power financials. I want to
share my experience and some of what I think is missing from the proposal, thoughts about the
IRP and some alternative proposals.
TABLES & CHART
I installed a 10.8 kwh nameplate system last JanuarV l2022l with the hopes it would cover most
of my annual needs. Given the current monthly netting system and the 1:1 kwh carryover
process - that hope has been realized.
Table 1
The first table shows my monthly generation, my monthly net amounts and the growing or
shrinking carryover. From March to June, I had accumulated just over 2000 kwh that then were
used in July and August. Favorable Sep results will help offset low Oct/Nov solar generation.
Bar Chart
The chart shows my entire 9 months of power generation so far. The 10.9 Mwh of total
generation is sliced by the hour of the day. Note my entire system is west facing. The blue bars
are the power generation. You can see the bulk of our power generation is between L and 6
PM. That's precisely when I use the least power, except for late afternoon AC in July & August.
Given the timing difference between generation and usage, I end up generating each hour what
ldaho Power calls Excess Energy. These are the Red bars. These are the excess Kwh sent to the
grid. This is the effect of real time measurement in the VODER study..
Table 2
The last table shows this same 10.9 Mwh separated into itt monthly buckets. You can see in
the total column that 58% of the 10.9 Mwh generated over 9 months that 58% of the power
generation would be "EXCESS" and subject to the lower rate if this is the measure (real time
netting) that is approved. ln some months, like May, this EXCESS is77% of total production.
Even in )uly,29o/o of the generation is "EXCESS" because of the timing difference between
generation and usage.
The yellow bars are the effect of Hourly Netting. The negative bars in the middle are the hours
where I am generating a net surplus and would be subject to the lower ECR rate. This last Table
shows that this would be 460/o of the overall solar power generation (total column.) ln the
month of May it would be73% of production - not far from the RealTime netting number.
The last lines of this table show the amount of "EXCESS" hours if the "Netting" were done on a
daily basis - NOT hourly or real time. I don't love this option but it would be a compromise that
is worth considering.
IMPACTS OF THIS PROPOSAL
lstrongly believe in at least 2 concrete results of this proposalas it presented.
1.) lf adopted as is. this proposal will quickly kill the residential solar industry. Many
analyses done by providers to residential customers show current payback in the 9-12 years
range. For me, this was marginally acceptable because of my interest in helping the
environment. This proposal makes those payback years double or triple depending on the
final measurement and ECR adopted. A 20-30+ yr payback is totally outside any reasonable
range and will be rejected every time. No one will invest.
2) This proposal will drive behavior change for residential players. A behavior change that is
diametrically opposed to the behavior ldaho Power wants. You tell me what the measures
are and I will adapt as best I can to maximize my benefit. I will shift my dishwashing, my
laundry and other power hungry activities to the 1-5 timeframe when I generate excess
power. ln the summer I will supercool my house during those peak production hours so that I
use my own power. I will hope it then relieves my use of expensive GRID power later in the
evening/night. That is precisely what ldaho Power doesn't want. They are offering S20 to
their customers who will relinquish control of their thermostat in the summer and live with
slightly higher temperature in order to conserve power during peak hours and help ldaho
Power avoid interruptions or blackouts. This VODER proposal completely screws up the
incentives for the behavior ldaho Power wants. lf one person does this, me for example, you
may say - we don't care. What if 10,000 of us did it, would you care? ldaho Power says solar
generators are being subsidized by non-solar customers. Maybe. ls it a material amount?
Maybe. But they can't claim we are a significant size and problem in terms of subsidization,
but then ignore any downside impacts because of immateriality. Either we are big enough to
matter or we are not. Beware of IDAHO POWER selectively choosing to add or ignore
benefits and risks.
MISSING EEMENTS IN THE VODER STUDYIPROPOSAL
FIXED COSTS
ldaho Power says 65% of costs are fixed. I believe them. I was in the accounting field for
Hewlett Packard for my career. I get that's its complex and I don't pretend to understand the
utility business in any detail. But I did hope to see more analysis that might lead to a potential
new fixed cost element of my bill instead of a variable rate change tied to my kWh usage.
lnstead of a variable rate change or the ECR, why not for example - a fixed charge based on your
system size. Say S5/month for a 1-5000 kwh system, St0/month for a 5001-10000 kWh system,
S1s/month for a 10,001- 15,000 kWh system. Whatever the numbers might be. I may not like
it any better, but I had hoped to see it.
ENVIRONMENTAL IMPACT
Ithink the whole environmental benefit/cost analysis is missing. ldaho Power acknowledges it's
not there and felt they didn't have a mandate or data to do it properly. On the surface you
might be disappointed but forced to accept this argument. However, if you look at ldaho
Power's 2021 IRP there are environmental considerations everywhere. For example on page
127 of the 2021 IRP there is a 20 year Carbon Price Forecast. Allthe trade-offs, costs, benefits,
timing, risks of shutting down the Bridger facility, consideration's for all the oil and gas fed
power utilities, how to get to L00o/o clean energy by 2035 or 2045 are included in the
lRP. Allthese are valid questions and valid analyses that ldaho Power wrestles with. They can
do it for residential solar - they just chose not to. ln the whole 200+ pages in the IRB the
residential solar business (benefits, risks, problems, issues, etc) is given a few paragraphs at
best. You would think ldaho Power is either ignoring it, doesn't care, or intends to quietly kill it.
A different vision of it is needed. And a real wrestling with the environmental issues.
CLEAR COST NUMBERS FOR HYDRO. WIND. SOLAR. COAL. GAS. THERMAL COMPONENTS
I had asked lP financial customer service employees for a cost comparison between hydro, coal,
gas, wind, solar in various forms, etc. The only thing I could get was a reference to the lRP. I did
find on page 109 something. lm not sure how to interpret things on it though, so I won't. But it
did make me wonder about 2 related things.
a) The 2 cent statement that go around for a solar ECR - what is the source of that?
b) They talked about cost avoidance, but did they talk about cost reduction? What if
they could get out ofthe coal and gas businesses sooner rather than later?
Could residential solar help accelerate this transition.
c) Biomass, small nuclear, and geothermal don't look cheap. Could residential solar
cost effectively replace them?
d) Maybe the answers to these questions are obvious, but they weren't to me.
Some straightforward disclosure of costs would help - even with its time of ay,
day of week, or seasonal complexities.
IDAHO POWER AND 3RD PARTY SYSTEM PROVIDERS COMMUNICATION ISSUES
Last, I want to comment on the communication of both industry providers and ldaho Power. lt
was fairly vague from both ldaho Power and industry providers. My wife and I finally had sit
down meetings with 2 providers about a year ago. One never brought any of this up - that a
study was being done and we wouldn't be grandfathered in. The second and the one we went
with, did a kind of a "oh yeah, you wont be grandfathered in, but don't worry about it."
Likewise the ldaho Power website states they "supports solar and customer choice." What is
that? Let's be clear this proposa!, if adopted, with a real time or hourly netting measurement
and a 2-4 cent ECR will killthe residential solar market here unless panel and installation costs
also drop in half. The surgeon general supports personal choice also but he also slaps a label on
every cigarette package saying it could kill you. lP should have a visible warning on its home
page saying residential solar is bad for your financial health. lt will never payback. And lndustry
partners should get a signed waiver saying the buyer understands. Admittedly, I did not do
enough homework. lt was on the edge of acceptability for me and we decided to do it for our
world' sake. Would I do it today. Absolutely not.
They al! need to be clear about risk, etc.
ALTERNATIVE PROPOSAIS. tthink there is a solution somewhere. And this VODER
proposal "ain't it".
1) Scrap the proposal and get a 3rd partyto do one.
2) Get a new team to make a proposal. Start with a very different vision. Get a team from
ldaho Power, 3rd Party Solar Providers and a citizen group (solar & non solar) together to be
locked in a room for 5 months and come out with a solution that is acceptable to everyone.
This is our planet, our homes, our livelihoods, etc. We can make this work.
3) lf some version of this proposal is accepted, please grandfather in to the current situation a
second group. Anyone who installed between Dec 2019 and your decision date around this
proposal should be grandfathered into the current system. Perhaps for a period of L0 years,
not 25 like the first group. That allows for a recovery of at least a substantial portion of the
investment.
4) Consider additiona! measurement options such as daily netting (easily done) or Fixed Cost
billing fees and mechanism rather than messing with the variable rate per kwh. This
however will require additional analyses and approval.